06 Special Code of Conduct for IT Positions

Chapter 1. General Provisions

1. Objective

The IT duty is a professional one requiring higher morals in its features than other general duty performers. Therefore, the Company shall impose additional moral obligations on duty performers to allow them to lead the Company’s business ethics.

The objective of this Special Code of Conduct for IT Positions is to establish a rightful corporate culture by maintaining the dignity of all Employees directly or indirectly related to the IT duties and the reputation of the Company, and securing transparency and security in the course of performing duties.

2. Coverage

This Special Code of Conduct for IT Positions shall apply to all Employees directly or indirectly related to the IT duties (hereinafter referred to as the “Duty Performers”) as follows:

• Persons for performing IT duties, including members in the IT sector that perform duties to develop programs, maintain and repair data processing, and operate computer; and
• All Employees that may directly or indirectly affect the decision-making related to the above duties.

If the Company regulations conflict with this Special Code of Conduct for IT Positions, the Company regulations shall be revised to meet the standards of this Special Code of Conduct for IT Positions.

3. The Operations of this Special Code of Conduct for IT Positions

All the Duty Performers shall confirm that they understand this Special Code of Conduct for IT Positions and submit a written pledge to observe this Special Code of Conduct for IT Positions.

Chapter 2. Principles of Performance of Duties

1. Objective

The duty performers shall clearly recognize that customer satisfaction is the source of the Company’s growth, and consider customers’ requests in conformity with laws, the first criteria for performing duties.

The duty performers shall establish the co-work system among relevant departments, and pursue the optimization of work functions through organic communication channels among duty performers.

The duty performers shall sufficiently figure out the requirements of the site departments regarding the data development and maintenance and repair and reflect them on the system operation and record and manage outputs at an appropriate level in the course of performing duties.

2. Transparency in Transaction Relations

Handling matters in a fair and transparent way regarding software services, designing for purchase of facilities, etc., evaluating applications for bid, performance of contracts, inspection of projects, etc. pursuant to relevant laws and the Company regulations.

Transaction relations with business partners shall be made based on contracts, and if there is a change in the agreement, the change(s) shall be recorded and managed pursuant to the appropriate procedures for performing duties.

The duty performers shall not exercise their influence or engage in unfair transactions or unethical activities by abusing their market positions.

3. Strict Information Control

The duty performers shall clearly recognize that not only the development, maintenance and repair related documents created, collected, or arisen in the course of performing duties but also relevant data development related matters, such as technologies and know-how are the Company’s assets, and shall strictly control them when it is brought out or in.

The duty performers shall not bring out or disclose to the outside any data processing system related matters (the outputs, source codes, etc.) and any information they have acquired in the course of performing duties without approval by the Company, and shall provide the information to authorized persons to an authorized extent.

The duty performers shall not acquire IT information in an unreasonable beyond the scope necessary to perform duties in unreasonable ways, and shall have the obligation to maintain security also for any information that they have come across by accident.

The duty performers shall systematically classify and control all data development, maintenance and repair related matters to create values, provide the matters to ensure that relevant duty performers can effectively use data, and the duty performers shall not at will distort or change relevant information.

4. Prevention of Conflicts of Internet

In the event that it is difficult for the duty performers to perform their duties fairly and efficiently because there are conflicts between the Company’s and their personal interest, they shall report it to Business Ethics Team and their superior manager.

If there is a report by the duty performers or a superior manager finds that conflicts of interest are likely to occur, the manager shall exchange the authorized person or take all measures for supervising duties.

5. Prohibited Activities

The duty performers in principle shall not perform the following works regarding their duties:

• Obtaining any and all monetary and non-monetary gains by receiving money and valuables, entertainments, conveniences from business partners or interested parties, having dual jobs with, receiving guarantee of employment of, or making investments jointly with the officer or employees of business partners, etc.
• Specifying requirements that may undermine fair competition in order to designate a specific company or product;
• Where a duty performer evaluates an application for bid, excluding a particular company without a special reason;
• Registering at will any unverified company;
• Changing the scope or term of project without approval by the Company after signing a contract;
• Unreasonably approving prior works by tolerating at will deterioration of quality, excessively calculating Man-Hour for development, etc.;
• Where a duty performer prepares a written proposal, doing it for a specific company (including a case where it is prepared by a specific company), designating special items or words for a specific company; provided, however, that in unavoidable cases, the duty performer shall manage such a proposal after obtaining approval from his or her superior manager.

Chapter 3. Handling Violations of Company Regulations

1. Reporting of Violations

The duty performers shall observe this Special Code of Conduct for IT Positions, and shall report to Business Ethics Team any matter that is or is likely to violate this Special Code of Conduct for IT Positions.

The Company ensures that all the matters on handling reports and the identities of reporters shall be kept in strict secret, and that any disadvantages shall not be given as a result of reporting; provided, however, that even if there is a fault on the part of a duty performer, where he or she has voluntarily reported it, the mitigating circumstances shall be taken into consideration.

2. Handling Violations and Taking Disciplinary Action

Business Ethics Team shall conduct investigation for violations reported and received, and report the results thereof to the CEO.

In the event that a duty performer has violated this Special Code of Conduct for IT Positions, he or she shall be subject to disciplinary action pursuant to the Company regulations.

Chapter 4. Additional Provisions

1. Effective Date

This Special Code of Conduct for IT Positions is enacted and effective from May 2, 2007.